Corcoran et al v. CVS Health Corporation

Northern District of California, cand-4:2015-cv-03504

Exhibit 34

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Exhibit 34 REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED Case 4:15-cv-03504-YGR Document 436-9 Deborah Filed 05/05/20 Page 2 of 9 Barrett September 16, 2016 1 Page 1 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 2 CASE NO. 15-CV-3504-YGR 3 4 Christopher Corcoran, Elizabeth Gardner, Tyler Clark, Michael Norkus, Zulema Avis, 5 Robert Garber, Toni Odorisio, Robert Guarnieri, Onnolee Samuelson, Robert Jenks, Debbie Barret, 6 Carl Washington, Robert Podgorny, Vincent Gargiulo, Zachary Hagert, Kevin Cauley, Linda 7 Krone, Carolyn Caine, Ken Bolin, Walter Wulff, Amanda Gilbert, and Gilbert Brown, on behalf 8 of themselves and all others similarly situated, 9 Plaintiffs, 10 -vs- 11 CVS Pharmacy, Inc., 12 Defendant. ___________________________________/ 13 14 DEPOSITION OF DEBORAH BARRETT Volume 1 of 1, Pages 1 through 294 15 Videotaped 16 17 Friday, September 16, 2016 8:39 a.m. - 4:12 p.m. 18 2701 Ponce de Leon Boulevard Suite 300 19 Coral Gables, Florida 33134 20 21 22 23 Stenographically Reported By: STEFANIE MENSCH, FPR, RPR, CRR 24 Florida Professional Reporter Registered Professional Reporter 25 Certified Realtime Reporter U.S. LEGAL SUPPORT (877) 479-2484 Case 4:15-cv-03504-YGR Document 436-9 Deborah Filed 05/05/20 Page 3 of 9 Barrett September 16, 2016 26 to 29 Page 26 Page 28 1 who are like you, gave testimony. And so their testimony 1 And do you remember talking on the phone to any 2 was transcribed, and the transcription of that testimony 2 other lawyer in connection with this litigation? 3 is called a deposition transcript. 3 A. No. 4 And so I'm asking: Did you review any deposition 4 Q. When did you -- when did you first meet 5 transcripts in the case? 5 Mr. Farrell? 6 A. No. 6 A. Physically meet, or ... 7 Q. Did you watch any videos of people giving 7 Q. Yes, in person. 8 testimony? 8 A. Today. 9 A. No. 9 Q. When did you first speak to Mr. Lewis on the 10 Q. Okay. Now, you mentioned some phone calls to 10 phone? 11 prepare for the deposition? 11 A. I don't remember. 12 A. Yes. 12 Q. And do you remember when you first spoke with 13 Q. How many phone calls did you have to prepare for 13 Mr. Farrell on the phone? 14 the deposition? 14 A. Yes. 15 A. Numerous over the last -- since last August. So 15 Q. When was that? 16 there were quite a few phone calls. 16 A. That was last, I would say, August. 17 Q. Since last August. When you say "last August," 17 Q. And how did that come to pass? 18 do you mean August 2016 -- 18 A. I was referred to Mr. Farrell for disability, 19 A. No. 19 social security disability, to take my -- you know, to 20 Q. -- or August 2015? 20 take my case. 21 A. 2015. 21 Q. Who referred you? 22 Q. Well, were all of those calls to prepare for this 22 A. I don't remember. It was on the Internet. 23 deposition, or were they just calls -- did that also 23 Q. Okay. Did you do some kind of search on the 24 include calls related to this case? 24 Internet to find Mr. Farrell's name? 25 MR. LEWIS: Yeah, I'll just object. It calls for 25 A. Actually, it was something that came up, and -- Page 27 Page 29 1 a legal conclusion. 1 about social security disability, and I inquired about it. 2 But answer to the best of your ability. 2 I made a phone call. 3 A. It was just preparation for documents that were 3 Q. And when you say you inquired about it, how did 4 needed to -- for me to provide, basically. 4 you inquire about it? 5 BY MS. SHUR: 5 A. I knew I had a disability and I needed -- I 6 Q. Okay. Well, how many calls -- the calls that 6 wanted legal counsel to help me with my claim. 7 related to this deposition, can you identify how many of 7 Q. And did any person give you Mr. Farrell's name? 8 those calls you had versus just general calls related to 8 A. No. It was something, like I said -- it's vague, 9 this litigation? 9 and I'm sorry -- 10 MR. LEWIS: Same objection. Please answer. 10 Q. That's okay. 11 A. I don't know. 11 A. -- but I don't remember. But I know I found it 12 BY MS. SHUR: 12 online, and then I got a phone call back. 13 Q. Do you remember how long the calls lasted? 13 Q. Okay. So in other words, there wasn't a person 14 MR. LEWIS: Objection. Vague. Please answer. 14 who recommended Mr. Farrell to you. 15 A. They could be anywhere from 10 minutes to an 15 A. Right. Right. 16 hour, basically, depending on the call. 16 Q. It was based on your Internet search; correct? 17 BY MS. SHUR: 17 A. Yes. 18 Q. And who was on those calls? 18 Q. So you originally contacted Mr. Farrell to 19 MR. LEWIS: Same objection. Please answer. 19 represent you in connection with your disability claim. 20 A. It was either Wes or Richard, Mr. Lewis. 20 A. Yes. Yes. 21 BY MS. SHUR: 21 Q. And that claim is the one you referred to earlier 22 Q. Okay. And when you refer to Wes, are you 22 in your testimony that is still pending? 23 referring to -- 23 A. Yes. 24 A. Mr. Farrell. 24 Q. I see. Okay. Have you paid any fees to 25 Q. Wes Farrell. Okay. 25 Mr. Farrell? U.S. LEGAL SUPPORT (877) 479-2484 YVer1f Case 4:15-cv-03504-YGR Document 436-9 Deborah Filed 05/05/20 Page 4 of 9 Barrett September 16, 2016 30 to 33 Page 30 Page 32 1 A. No. 1 Pharmacy, Inc., along with a number of other individually 2 Q. Do you have a retainer agreement with 2 named plaintiffs. So that's what I'm referring to when I 3 Mr. Farrell? 3 say "Corcoran litigation." 4 A. Yes. 4 Does that clarify it? 5 Q. So are you paying Mr. Farrell on a contingency 5 A. Yes. 6 basis? 6 Q. Okay. So now let me repeat my question. When 7 MR. LEWIS: Objection. That's a matter of 7 did you retain Mr. Farrell in connection with the Corcoran 8 attorney-client privilege. Do not answer that 8 litigation? 9 question. 9 A. I believe it was -- I'm not sure. 10 MS. SHUR: Well, Counsel, I don't think that the 10 Q. Do you remember whether it was August of 2015? 11 fee arrangement is subject to the attorney-client 11 A. It was around the same time as -- yes, it was 12 privilege. Of course, you can instruct the witness 12 August. 13 as you deem fit, but that -- I'm not asking for her 13 Q. And how did that come to pass? 14 to disclose any attorney-client privileged 14 A. Just in -- 15 communications. I'm asking about the nature of a fee 15 MR. LEWIS: I'm going to instruct you to please 16 arrangement that she has, and we're entitled to ask 16 answer, but do not disclose anything you said to 17 about that. 17 Mr. Farrell or anything Mr. Farrell said to you. And 18 MR. LEWIS: Yeah. I'll instruct you not to 18 please answer. 19 answer that question. 19 A. It just came up as part of our conversation 20 BY MS. SHUR: 20 with -- regarding my disability. 21 Q. Okay. And I'll just ask you for the record: Are 21 BY MS. SHUR: 22 you going to follow your attorney's advice and not answer 22 Q. Before you spoke to Mr. Farrell, did you have any 23 my question? 23 belief that CVS had done anything wrong? 24 A. Yes. 24 A. No. 25 Q. Now, have you retained Mr. Farrell to represent 25 Q. Did you believe CVS had overcharged you? Page 31 Page 33 1 you in connection with this litigation also in addition to 1 A. No. 2 the disability claim litigation in which he is 2 Q. Have you ever spoken with Bonnie Sweeney? 3 representing you? 3 A. No. 4 A. Yes. 4 Q. Do you know who that is? 5 Q. When did you retain him to represent you in 5 A. Yes. 6 connection with the Corcoran litigation? 6 Q. Who is that? 7 MR. LEWIS: Counsel, if you clarify "Corcoran 7 A. She's part of the team for the plaintiff. 8 litigation," I think it might help. 8 Q. When you say "part of the team for the 9 BY MS. SHUR: 9 plaintiff," what do you mean by that? 10 Q. Okay. Sure. So -- and by the way, if you need 10 A. Part of the team of lawyers. 11 clarification, you should absolutely ask me, and I will 11 Q. Okay. What about Kristin Ward Broz? 12 clarify any time. 12 A. No. 13 So do you understand what the Corcoran litigation 13 Q. Do you know who that is? 14 is? 14 A. That's also part of the team. 15 A. I -- yes. 15 Q. What about -- and you've never met or spoken with 16 Q. What is the Corcoran litigation? 16 her? 17 A. Corcoran is the attorney for CVS, the -- the 17 A. No. 18 defendant. 18 Q. And just to be clear, you've never spoken or met 19 Q. That is your understanding of the Corcoran 19 with Bonnie Sweeney? 20 litigation? 20 A. No. 21 A. Yes. 21 Q. What about Pat Cipollone? Do you know who that 22 Q. Okay. What I'm talking about when I say 22 is? 23 "Corcoran litigation" is the litigation in which you are a 23 A. He's also part of the team? 24 named plaintiff that is pending in the Northern District 24 Q. Have you ever met or spoken with him? 25 of California, in connection with which you are suing CVS 25 A. No. U.S. LEGAL SUPPORT (877) 479-2484 YVer1f Page 38 Page 40 1 BY MS. SHUR: 2 Q. Do you know if there's a document outlining the 3 terms of Mr. Lewis's representation of you? 3 Q. So the basis for your belief that you were being 4 A. No. 4 overcharged by CVS is that you are paying less at a 5 Q. No, you don't know? 5 different pharmacy currently? 6 A. I don't know. 6 MR. LEWIS: Objection to time frame. 7 Q. Now, I'm not asking you for how Mr. Lewis or your 7 Please answer to the best of your ability. 8 lawyers are being compensated, but do you know what the 8 A. Yes. 9 compensation arrangement is? 9 BY MS. SHUR: 10 A. No. 10 Q. Is that the only basis for your belief that CVS 11 Q. You do not know? 11 overcharged you? 12 A. (Witness shakes head.) 12 MR. LEWIS: Same objection regarding discussions 13 Q. And can you speak audibly? Sorry. 13 with counsel. 14 A. Sorry. 14 Please answer. 15 Q. That's okay. 15 A. Yes. 16 A. No. 16 BY MS. SHUR: 17 Q. No. 17 Q. Are you currently paying less for both of the 18 A. I don't know. 18 medications that you just mentioned? 19 Q. Have you paid any fees or costs to anybody in 19 A. Yes. 20 connection with the Corcoran litigation? 20 Q. How much less are you paying? 21 A. No. 22 Q. Now, we've already discussed that you are a 23 plaintiff in the Corcoran litigation; yes? 24 A. Yes. 25 Q. And so tell me, how did you become involved in Page 39 1 the lawsuit? 2 MR. LEWIS: Please answer without disclosing 3 anything that you discussed with Mr. Farrell or me or 4 that you said to us or we said to you. 5 A. I became involved as part of -- during my 6 disability conversations. 7 BY MS. SHUR: 8 Q. And what prompted you to decide that you wanted 9 to be involved in the Corcoran litigation? 10 A. Because I felt if -- if CVS is overcharging, it's 11 fraud. It's not right. And I felt that, you know, it 12 should be corrected. 13 Q. Do you believe that CVS has overcharged you? 14 A. Yes. 15 Q. On prescription medicines? 16 A. Yes. 16 Q. Okay. But you began to participate in the 17 Q. What is the basis for your belief? 17 Corcoran litigation before April -- I'm sorry. Strike 18 MR. LEWIS: Same instruction as before. Please 18 that. 19 answer to the best of your ability without disclosing 19 When you say "April 1st," you mean April 1st of 20 what you said to counsel. 20 2016 as to both medicines; right? 21 A. Just a specific prescription that I take that I 21 A. Yes. 22 now am paying a lot less for at another pharmacy. 22 Q. But you -- your involvement in the Corcoran 23 BY MS. SHUR: 23 litigation predates April 2016; correct? 24 A. Yes. 25 Q. So then what is the basis -- what was the basis Page 42 Page 44 1 of your understanding that you were overcharged before 1 you are participating in the Corcoran litigation? 2 April 2016, before you were paying any less for your 2 A. No. 3 medications? 3 Q. What amount of money do you hope to recover in 4 MR. LEWIS: Same objection. Please answer 4 the Corcoran litigation for yourself? 5 without disclosing what you said to counsel or what 5 A. I don't know exactly. I think it's maybe about 6 counsel said to you. 6 $80. 7 A. I didn't know at that time. 7 Q. You think the overcharges total -- 8 BY MS. SHUR: 8 A. Yes. 9 Q. If you didn't know that you -- whether you were 9 Q. -- about $80 or so? 10 being overcharged, why did you become involved in the 10 A. Yes. 11 Corcoran litigation? 11 Q. Do you know the legal name of the entity that you 12 MR. LEWIS: Asked and answered. Please answer 12 are suing? You're suing CVS, but I'm asking you: Do you 13 again without disclosing what you said to counsel or 13 know the full name of that entity? 14 what counsel said to you. 14 A. No. 15 A. Can you repeat the question? 15 Q. Do you know if you originally sued any other 16 BY MS. SHUR: 16 entity apart from the entity that is currently named in 17 Q. Absolutely. So when you first became involved in 17 the litigation? 18 the Corcoran litigation, why did you decide to become 18 A. No. 19 involved, since at that point in time, you had not yet 19 Q. And I think we already established this, but just 20 begun to pay less for the two medicines that you've 20 to make sure the record is clear, is it correct that you 21 identified? 21 first contemplated suing CVS Pharmacy, Inc., in August of 22 MR. LEWIS: Same instruction. Please answer. 22 2015? 23 A. Because I had faith that the lawyers were doing 23 A. Yes. 24 their job to investigate, and I went by the -- that 24 Q. Now, when you retained Mr. Farrell in connection 25 premise. 25 with your disability claim, did you provide Mr. Farrell Page 43 Page 45 1 BY MS. SHUR: 1 your CVS pharmacy records? 2 A. Yes. 3 Q. What other documents did you provide Mr. Farrell? 4 A. Well, for the disability, I had to give my 5 medical records and all documentation of any medical 6 procedures. Whatever they asked me for. I don't remember 7 everything. 8 Q. Do you understand that the Corcoran litigation is 9 a class action lawsuit? 10 BY MS. SHUR: 10 A. Yes. 11 Q. And did you conduct any investigation of your own 11 Q. Do you know what a class action lawsuit is? 12 to confirm what your attorneys were telling you? 12 A. Yes. 13 A. No. 13 Q. Can you tell me what your understanding -- 14 Q. Have you told me all of the reasons why you are 14 A. To the best of my ability, it's a case where it 15 participating in the Corcoran litigation? 15 involves a class of people, representatives from different 16 A. I don't know. 16 areas, to -- to represent a whole group. 17 Q. Well, let me ask it a better way then. Other 17 Q. And what is your understanding of the group that 18 than what you've already testified to, why are you 18 you are representing as a class representative, or a 19 participating in the Corcoran litigation? 19 putative, I should say, class representative? 20 A. I'm participating because if there is deception 20 A. I don't understand. 21 or fraud, if there is overcharge, I think it's wrong. And 21 Q. Well, what group -- so when I use the word 22 I just want to either get my money back or make it stop so 22 "putative," what I mean by that is simply that the court 23 that nobody else pays any more than they have to for 23 has not yet ruled on whether you could or could not be a 24 generic drugs. 24 class representative. So that's why I said "putative." 25 Q. All right. And is there any other reason that 25 But what group of people do you understand that Page 58 Page 60 1 Q. Okay. 1 A. Okay. 2 A. No, I don't remember. I take a lot -- I take a 3 lot of medication. 4 Q. Okay. Well, but this pleading, at least, only 5 identified four monthly maintenance medications, correct? 6 A. Yes. 6 Q. Okay. But that's a guess? 7 Q. And then below that, it says "Barrett - 7 A. Yes. 8 Prescription 2." Do you see that? 8 Q. Now, if you turn to page 59, do you see that on 9 A. Yes. 9 page 59, paragraph 597, it states that "CVS overcharged 10 Ms. Barrett at least $38.81 between November 16, 2013 and 11 July 12, 2015"? Do you see that? 12 A. Yes. 13 Q. Sitting here today, do you believe that that is 14 an accurate figure with respect to the alleged overcharges 15 that you're claiming? 16 A. I don't know. 17 Q. Did you calculate this figure, $38.81? 18 A. No, I didn't. 19 Q. Do you know how it was calculated? 20 A. No. 21 Q. Do you know one way or the other whether it's 22 correct? 23 A. I don't know. 24 Q. Do you see in paragraph 542, there's a reference 24 Q. And do you know whether -- one way or the other 25 to the CVS HSP generic medication list? 25 whether it was correct at the time that this pleading was Page 59 Page 61 1 A. Uh-huh. 1 filed? 2 Q. And that's a yes? 2 A. I don't know. 3 A. Yes. I'm sorry. 3 Q. Let me hand you Defendant's Exhibit 82, which is 4 Q. That's okay. Do you know what "HSP" refers to? 4 the second amended class action complaint in this case. 5 A. No. 5 Now, have you seen Defendant's Exhibit 82 before? 6 Q. Do you know what "Health Savings Pass" refers to? 6 A. I believe so. 7 A. No. 7 Q. Do you recall when you first saw it? 8 Q. Do you see in paragraph 545 on that same page a 8 A. No. 9 reference to "U&C"? 9 Q. Do you recall when you last saw it? 10 A. Yes. 10 A. I believe it was probably yesterday. 11 Q. Do you know what "U&C" refers to? 11 Q. And did -- did you authorize its filing? 12 A. No. 12 A. Yes. 13 Q. Do you know what "usual and customary" refers to? 13 Q. Did you review -- I'm sorry. 14 A. No. 14 You understand that this document was filed in 15 Q. If you turn to the next page. 15 court -- 16 A. Okay. 16 A. Yes. 17 Q. Do you see that it says "Barrett - Prescription 17 Q. -- Defendant's Exhibit 82; yes? 18 3" there? 18 A. Yes. 19 A. Yes. 19 Q. Did you review Defendant's Exhibit 82 before it 20 Q. Do you know what Prescription 3 is? 20 was filed? 21 A. No. 21 A. Yes. 22 Q. What medicine it is? 22 Q. Do you have an understanding as to why the first 23 A. No. 23 amended pleading was amended? 24 Q. And then if you go to page 57, there's a 24 MR. LEWIS: Objection. Calls for a legal 25 reference to "Barrett - Prescription 4." 25 conclusion. Case 4:15-cv-03504-YGR Document 436-9 Deborah Filed 05/05/20 Page 8 of 9 Barrett September 16, 2016 90 to 93 Page 90 Page 92 1 asking you -- if you look -- if you look toward the top of 1 BY MS. SHUR: 2 the page -- 2 Q. Let me hand you what I'm going to mark as 3 A. Yes. Yes. 3 Defendant's Exhibit 217. And these are your second 4 Q. -- it says "Interrogatory No. 3," and what it's 4 amended responses and objections to defendant's 5 asking you is to identify any pharmacy where you've filled 5 interrogatories. 6 prescription medicines since November 1, 2006 to the 6 MR. LEWIS: Thank you. 7 present. Do you see that? 7 BY MS. SHUR: 8 A. Yes. 8 Q. And, I'm sorry, I just -- I have another question 9 Q. Okay. So you've identified Liberty Pharmacy as a 9 respecting Defendant's Exhibit 215, the prior document we 10 pharmacy you have used from April 1, 2016 to the present. 10 were reviewing. 11 A. Yes. 11 A. Okay. 12 Q. And is that the only pharmacy you've used from 12 Q. If you look on the last page of that document, do 13 April 1, 2016 to the present? 13 you see a verification there? 14 A. Yes. 14 A. Yes. 15 Q. Why do you -- why did you decide to use Liberty 15 Q. Did you sign that? 16 Pharmacy? 16 A. Yes. 17 A. I use Liberty. My husband has used them. And I 17 Q. That's your signature? 18 had gone into Liberty when I knew I was getting different 18 A. Yes. 19 insurance, and I gave them a list of the medications I 19 Q. And did you date that? 20 take. And I had asked them what they would -- what it 20 A. Yes. 21 would cost me for it, and it was considerably less. So I 21 Q. So did you verify these interrogatories on the 22 switched to Liberty. 22 27th of August? 23 Q. And did Blue Cross/Blue Shield require you to use 23 A. Yes. 24 Liberty? 24 Q. And you'll see that the interrogatory responses 25 A. No. 25 are dated September 12, 2016, if you look on the page Page 91 Page 93 1 Q. But your husband informed you that he used 1 immediately before your verification. 2 Liberty? 2 A. September 12th? 3 A. Yes. 3 Q. Yes. 4 Q. Now, from November 1, 2006 to the present -- 4 A. Okay. 5 setting aside for now CVS -- have you used any other 5 Q. Do you have any explanation as to why you 6 pharmacies to fill any kinds of medicine or prescriptions? 6 verified these on August 27th, but CVS was not served 7 A. No. 7 until September 12th? 8 Q. None at all? Only CVS from November 1, 2006 to 8 MR. LEWIS: Object to foundation. Calls for a 9 the present? 9 legal conclusion. 10 A. Yes. 10 Please answer. 11 Q. What about before November 1, 2006? Have you 11 A. I don't know. 12 ever used any pharmacies apart from CVS and Liberty 12 BY MS. SHUR: 13 Pharmacy? 13 Q. Do you recall when you provided your verification 14 A. No. 14 page to your counsel? 15 THE VIDEOGRAPHER: Counsel, can we go off the 15 A. It would be on the date I signed it. 16 record again? 16 Q. How did you -- how did you provide it to your 17 MS. SHUR: Okay. 17 counsel? 18 THE VIDEOGRAPHER: Off the video record at 18 A. I probably had it FedExed back to the office. 19 10:35 a.m. 19 Q. And what documents did you have before you when 20 (A break was taken from 10:35 a.m. to 10:35 a.m.) 20 you -- when you verified this -- these interrogatory 21 THE VIDEOGRAPHER: Back on the video record at 21 responses? 22 10:35 a.m. 22 A. I don't understand. 23 (Plaintiff Debbie Barrett's Second Amended Responses 23 Q. When you signed the verification page, did you 24 and Objections to Defendant's Interrogatories was marked 24 have any documents with you? 25 for identification as Defendant's Exhibit No. 217.) 25 A. I had the documents that I signed. U.S. LEGAL SUPPORT (877) 479-2484 YVer1f Case 4:15-cv-03504-YGR Document 436-9 Deborah Filed 05/05/20 Page 9 of 9 Barrett September 16, 2016 290 to 293 Page 290 Page 292 1 CERTIFICATE OF REPORTER 1 that date? 2 2 A. Yes. 3 STATE OF FLORIDA 3 Q. Do you think it's a retainer agreement or 4 COUNTY OF MIAMI-DADE 4 something else? 5 5 A. I'm not sure. 6 I, Stefanie Mensch, Florida Professional Reporter, 6 Q. Okay. I don't have any further questions for you 7 certify that I was authorized to and did stenographically 7 at this time. I appreciate you coming to testify. Thank 8 report the deposition of Deborah Barrett, pages 1 through 8 you. 9 290; that a review of the transcript was not waived; and 9 MR. LEWIS: Thank you. 10 that the transcript is a true record of my stenographic 10 MS. SHUR: And we just -- just for the record, 11 notes. 11 you know, we've made some document requests, and we 12 I further certify that I am not a relative, 12 reserve the right to question the witness about any 13 employee, attorney, or counsel of any of the parties, nor 13 additional documents or supplemental discovery we 14 am I a relative or employee of any of the parties' 15 attorneys or counsel connected with the action, nor am I 14 receive. 16 financially interested in the action. 15 MR. LEWIS: Thank you. No questions from the 17 16 plaintiffs. 18 Dated this 23rd day of September 2016. 17 THE WITNESS: Thank you. 19 18 THE VIDEOGRAPHER: Off the video record at 20 19 4:12 p.m. 21 _________________________________ 20 ------ Stefanie Mensch, FPR, RPR, CRR 21 (The deposition was concluded at 4:12 p.m.) 22 Florida Professional Reporter 22 (Reading and signing of the deposition was not waived Registered Professional Reporter 23 by the witness and all parties.) 23 Certified Realtime Reporter 24 24 25 25 Page 291 Page 293 1 CERTIFICATE OF OATH 1 WITNESS NOTIFICATION LETTER 2 September 26, 2016 2 Ms. Deborah Barrett Robkoff 3 STATE OF FLORIDA 3 c/o Richard Lewis, Esq. 4 COUNTY OF MIAMI-DADE Hausfeld 4 1700 K Street N.W., Suite 650 5 Washington, D.C. 20006 6 I, Stefanie Mensch, Florida Professional Reporter, 5 7 Notary Public, State of Florida, certify that Deborah In Re: Christopher Corcoran, et al. Vs. CVS Pharmacy, Inc. 8 Barrett personally appeared before me on the 16th day of 6 Deposition taken on September 16, 2016 U.S. Legal Support Job No. 1460768 9 September 2016, and was duly sworn. 7 10 Signed this 23rd day of September 2016. The transcript of the above proceeding is now available 11 8 for your review. 9 12 10 13 ____________________________________ 11 STEFANIE MENSCH, FPR, RPR, CRR Please complete your review within 30 days. 12 14 Notary Public, State of Florida 13 Commission No.: FF116067 14 Very truly yours, 15 Commission Expires: July 21, 2018 15 16 16 17 Stefanie Mensch, FPR, RPR, CRR 17 Florida Professional Reporter 18 18 U.S. Legal Support, Inc. One SE Third Avenue, Suite 1250 19 19 Miami, Florida 33131 20 (305) 373-8404 21 20 CC: Via Transcript 22 21 Luba Shur, Esq. 23 22 24 23 24 25 25 U.S. LEGAL SUPPORT (877) 479-2484